Shipley Group: [00:00:00] Welcome to the NEPA Project, a monthly podcast discussing NEPA and other environmental topics. In this episode, we will discuss 10 Tips for NEPA Success.

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The guests on this episode will be Judy Kurtzman and Rhey Solomon. Judy Kurtzman worked for Utah State University, in the Quinney College of Natural Resources for over 15 years. While at the University she taught courses on NEPA and other environmental laws for undergraduate and graduate level students, and administered the NEPA Certificate Program offered in partnership between Utah State University and Shipley Group. During the last 12 years she has also taught for the Shipley Group. Rhey Solomon retired from the Forest Service in 2003. After 32 years of government service and is now an independent environmental consultant. Rhey served as the deputy director of ecosystem management in the Washington office before retirement. Let's get to the conversation.

Rhey Solomon: [00:01:30] What we're here to talk about today are what we call the 10 tips in the NEPA success. Let me just quickly go through those 10 points and then we'll come back and deal with each. Very specifically the first is is the need for action compelling. The first one the second is are your action and actions specific. So one can understand what you are doing including connected actions. Number three are your issues that are derived from those actions tied to the action. So there's a direct cause/effect link. Number 4 is as you modify your action is it clear how you modify that response to the issues. Number 5. Are all your reasonable alternatives identified and dealt with. Number 6. Are those alternative actions in their effects compared in a succinct direct way. Number 7. Are the methods of analysis transparent and supported by appropriate science. Number 8. Are your assumptions that were made clear and have you dealt with the unknown factors and weaknesses in your methodology. Number 9. Can you show how you've consulted with other agencies and particularly the public in arriving at your analysis in decision making. And Number 10. Is everything documented in the record.

Rhey Solomon: [00:03:15] So with that Judy I"m going to turn it to you for the first item.

Judy Kurtzman: [00:03:21] So the first item is determining whether or not the need for the action is compelling. In other words is this a good a good project or a good policy that we are implementing. And the best way to make that determination, Rhey, I think, is through brainstorming. I don't I don't think it's a good idea for one person to sit down and basically write up a purpose and need statement, explaining the importance of the project. That it requires a number of different perspectives for developing a really good purpose and need statement that determines whether or not this action is really compelling or whether we really need to move forward on this or not. And the interdisciplinary teams can provide that and they are coming at it from different perspectives, different disciplines and identifying different issues.

Rhey Solomon: [00:04:32] Yeah I also ask them to take a look at how your detractors. How would your detractors define this problem from their perspective. And that often gives you a different lens to look at the project, rather than a very narrow lens that an agency typically looks at your project.

Judy Kurtzman: [00:04:53] Absolutely. It also gives you the perspective of the public thats most likely to, as you said, see the detractors, that will fight you on it. So that before you even move into the area of going forward with the action you are well aware of what some of the contrary ideas are going to be.

Rhey Solomon: [00:05:22] Yeah and as some practitioners do they will actually take some of those other perspectives and they separate out the need from the purposes. And some call those purposes objectives. And actually frame an objective or a purpose. That emphasized the other perspective.

Judy Kurtzman: [00:05:46] Which I think is a really good idea yeah. So youve addressed it before people had even had a chance to criticize you for it. And you have not only addressed it, but you've addressed it hopefully in a way that will reduce their concerns.

Rhey Solomon: [00:06:03] Yeah I think that's the essence of why you try to define that scope so it then directs the rest of the analysis.

Judy Kurtzman: [00:06:13] Exactly. So really getting that purpose and needs statement defined and thought through deeply. And from different perspectives is going to help ensure that the entire NEPA process the documentation and analysis that are required will be well structured and hopefully well focused.

Rhey Solomon: [00:06:42] Yes I agree with that. Assuming that is properly defined then the next item is to look at specifically what is the action that you are actions that you are proposing which of course includes connected actions and I find practitioners tend to define those actions too broadly. I tell them I want to know who's proposing it. Where its being done. What's being done. How it is being done. And when it's being done. And often I find causes real difficulties for people to understand that not all of your proposed actions are taking place at the same time or the same place. And so you need to be more site specific in describing those so that when you do the effects analysis your subject matter experts know specifically where the effects are going to occur because you properly define where the action are going to occur and when they're going to occur. Any thoughts on that?

Judy Kurtzman: [00:07:55] Yes I do. And and one of the things. Well there are two things actually. What do you think about similar actions Rhey? It seems to me that that's a little bit of a murky area. And the courts have kind of come up with the different perspectives on it and I think there's some confusion. And for me their is some confusion related to what the courts have said because in one instance well in both instances were timber harvests. And in one instance the courts said because they're happening in the same water shed. They're happening within 18 months of each other they are similar actions. And rather than doing three EAs you should do one document and analyze them together. Another court said we need to defer to the agency. Even though these are three timber harvests within the same watershed. Within a two year period and now all be using the same method of harvest. We need to defer to the agency to determine whether they should be doing one document or three documents. So what are you thoughts on that?

Rhey Solomon: [00:09:14] I always tell folks when you're looking at that what you are going to combine similar actions like timber sales or oil development or pipelines whatever. That I always tell them you need to take a look at is the environment that encompasses that large geography because you typically have expanded that geography. Is the environment or the ecosystems are they similar? Are your vegetation types similar? Are your soils similar? Are your water responses similar? Does your public is your public on board with looking at a larger geographical scale? Do you have the technical data and information at the smaller scale where you can aggregate up in order to look at that larger scale? So I think there's a lot of factors that not only does the agency need to look at but I think the agency needs to describe why they believe they can expand that geographical scope. As they expand their scope of the projects and maintain the site specificity of analysis.

Judy Kurtzman: [00:10:34] Or vice versa. I think they need to give their rationale if they're not going to do it at the larger area. And you make really good points there because if we are looking at different ecosystems then analyzing that altogether would be kind of a nightmare.

Rhey Solomon: [00:10:54] And the pendulum has swung back and forth on this over the last probably 30 years where agencies particularly land management agencies for the sake of trying to make their analysis more efficient have looked at larger landscapes as a multiple projects. And when they do so their analysts then tend to not write the environmental effects to the same level of specificity. They write them very generally and then they find the courts will say well you've written it at a program level rather than at a project level and therefore you lose.

Judy Kurtzman: [00:11:37] Right now you know the connected actions are pretty self-explanatory. But its those similar actions that I think agencies need to think about when they're writing up their purpose and need statement. And and I agree with you 100 percent giving your rationale as to and maybe not in your purpose and need statement maybe in your cumulative impact assessment as to why you provided certain projects into different environmental assessments or impact statements.

Rhey Solomon: [00:12:12] Yeah I think that's right. And so then once you've got once you've got the your, your purpose and need and you've got this project well-defined. Then we can move to the to the third tip which is what what problems does that project now create for you? What are those issues that results from you taking the action that you have now described? I find that practitioners often immediately just brainstorm an issue without really thinking about what is the causitive mechanism of the action that leads to that effect. Because if you don't do that if you then come back and want to apply mitigation measures or another alternative you have to interrupt that cause effect chain of the action leading to an effect in order to show how effective your mitigation measure is. And sometimes I see these issues one being defined very broadly but more importantly they're not described in a way that shows the action results in this kind of intermediate effect which then ends up creating this unacceptable end point that we now are going to have to mitigate.

[00:13:45] And I think it's really important in the issue statements that one draws that link between the causitive action and the end point effect that they're really concerned about.

Judy Kurtzman: [00:13:55] And are you think that that needs to be done then in Chapter 2 when they are defining their proposed action and other alternatives. And the specificity in which they define them?

Rhey Solomon: [00:14:12] You know you bring up an excellent point and I see it done in one of two places either at the end of the purpose and need section where they typically talk about public involvement. And as as a result of that and they derive their issues. I've seen it done there. Or it can be done at the very beginning in the alternative section in describing how you develop the alternatives. And I tell practitioners I personally don't care where it is as long as you can tell your story and you make the transition from the person needs section into the alternative section.

Judy Kurtzman: [00:14:58] Yes absolutely. And normally I I recommend also that they go in chapter one at the at the end of Chapter 1. The list of these other relevant issues we determined will be carried through and then here are the non relevant issues. And here's how we've come to the conclusion they're non-relevant. One of the my concerns. I have often seen in chapter one a proposed action that the title proposed action and then a description of the proposed action in chapter 1 which should never happen because it's an alternative. And now you have narrowed your purpose and to one alternative and you've eliminated the ability for other alternatives to meet that purpose and need because it is so narrow. So how do you avoid doing that?

Rhey Solomon: [00:15:56] Well I think the way I do it is if I'm running into that issue. I bring that discussion in to the beginning of the alternative section. And I actually have a subsection that I label "development of alternatives" and that's why I then take my proposal and say Here are the issues that are derived from that proposal. And here is how we have taken these issues and formulated other equally viable alternatives. And I tell my story by showing how I started with the proposal but now that led me to these issues that cause me to look at another broad array of alternatives. The alternatives are so much let's brainstorm. They're more driven by the environmental and I include social and economic in that package. They are driven by the issues that are created by my proposal. Because if I don't have issues. I'm not going to go create alternatives for the sake of creating alternatives. Thats a really inefficient way to do analysis.

Judy Kurtzman: [00:17:10] Completely. Which then kind of leads us in to number 4. Because as you just said. A lot of times the differences between alternatives are the mitigation measures addressing the issues and mitigation measures that need to be analyzed even if they are not part of an alternative as required by 1502.14 the CEQ regs. So that decision makers and the public have an opportunity to see what mitigation measures would be possible and available to avoid, reduce, rectify etc. those issues.

Rhey Solomon: [00:17:55] That leads me to the idea of a what I call "mytigi". One of my pet peeves in the subject matter experts is that not to be picking on wildlife biologists in particular but that I find what they do is you have an alternative that's got a number of issues and they'll throw everything and the kitchen sink at it. And you've got 30 mitigation measures and they can never tell you how effective those individual mitigation measures going to be. It just drives me nuts that if one is going to put a mitigation measure associated with some unacceptable environmental consequence. You ought to be able to tell me two things: how much is it going to cost? And what is the incrimental benefit to the environment by adding that mitigation measure. And I think by doing that you force your subject matter experts to really be thinking about the effectiveness and the efficiency of mitigations that they're going to require the agency to implement.

Judy Kurtzman: [00:19:04] Yes I agree and what you'll often see is well. We've got best management practices and we will implement those, so just trust us on that. And we're not going to list what they are but there are 45 of them in appendix E and we will be implementing the ones appropriate but we don't know which ones we are implementing and it's a big "trust us" statement which is also one of my pet peeves.

Rhey Solomon: [00:19:33] Absolutely. And what bothers me about that is that then every subject matter expert that is on your team makes different assumptions about which mitigation measures are actually going to be applied and it then makes the analysis subject to an individual subject matter experts interpretation rather than the whole team being in sync on what those mitigation measures are.

Judy Kurtzman: [00:20:04] Exactly. There are situations where the differences between the alternatives is one has mitigation measures in it and another might not or might have fewer. I agree with you just saying we're just going to throw all these mitigation measures in so trust us it will all be okay. And then not really necessarily even seeing them analyzed or seeing them analyzed from a different perspective depending upon the subject matter expert.

Rhey Solomon: [00:20:35] Which then takes us right into the fifth one which is this the development of the alternatives and looking at those reasonable alternatives that I find another failing is agencies don't take credit for some of those alternatives and mitigation measures that they have considered but then decided that for one reason or another are not going to be used or applied either as an alternative or as a mitigation measure. And those you get credit for that. If you can show you've talked about it. So I always look for a section in documents, EAs as well that are alternatives considered but dismissed for detailed consideration. And I often find thats left out.

Judy Kurtzman: [00:21:30] And it is part of the CEQ regulation. Again, 1502.14 They talk about the alternatives you considered and eliminated and why you eliminate them. And that's especially helpful if you only have one action alternative there. You know there's this idea that and I don't want to pick on lawyers but there's this legal idea that there has to be at least two action alternative and the no action alternative and some agencies as a result of that will put in these fake alternatives that are very obviously fake alternatives and they're not. You can tell they're not honestly being considered because they don't either meet the purpose and need very well or there's something about them that they're not well described. They're not well developed. And then there goes the credibility for the document because Chapter 2 has fake alternatives and I think that's harmful. So I agree with you that if you only have one just describe the one that you did consider and then eliminated. And that's the best you can do.

Rhey Solomon: [00:22:46] Yeah. And again this goes back to that that string of the issues that if you have a robust list of issues it would follow that you should have a greater number of alternatives if you don't have a whole lot of issues then you shouldn't have. You shouldn't go out and just create these false alternatives for the sake of creating alternatives. Again you should be able to narrow that down as you go.

Judy Kurtzman: [00:23:18] Right. Exactly. And this becomes a lot less predecisional if you've done than that. Explain that explaining that people have mentioned the story behind behind it so that they understand how you came to the alternatives you did look at or why you only have one alternative or one action alternative.

Rhey Solomon: [00:23:43] Yeah yeah. You know that brings us to our 6th point which is this idea of a comparison of the alternatives. This is another failing. I don't know why it is such a failing that many practitioners assume that the environmental effects and the comparison of those effects should be done in the effects section of the document. And although the rationale for those effects or in the effects section the actual comparison of those effects should be brought right up front in the alternative section. It's called the heart of the environmental document. And it should sharply contrast the merits of the alternatives. The only way you can do that is by having some display whether it's tables, diagrams, graphs whatever they are to sharply contrast the merits of the alternatives. And I find that consistently lacking in the alternative section.

Judy Kurtzman: [00:24:59] Yes I agree and I talk to the agencies about that and they say well we did that in at the end of chapter 4. Because it makes more sense because now you know you have discussed all of these impacts. And my recommendation for them is to move it in to chapter 2 where it is right behind the alternatives. First of all, that can the serve the chapter 1 and 2 to make sure that the executive summary that decision maker and the public can can review and they don't need to read Chapter 3 and 4 unless they want to get into the technical aspects of it. Everything is in chapter 1 and 2 with that and I prefer a matrix that I can see where you could do with the diagram as well. But showing here are the resources, here's the current condition of them, here is how they change under no action. Here is how they change under alternative B. And if you put it in Chapter 4 a lot of people they will never got to the end they never see it at the end of Chapter 4.

Rhey Solomon: [00:26:14] Well. What I tell folks when I'm doing reviewing documents I say take alternatives chapter out as a separate entity. Could your decision maker make a decision based on what is in Chapter 2? If they cant you don't have what should be in Chapter 2.

Judy Kurtzman: [00:26:38] I like that. I like that a lot right.

Rhey Solomon: [00:26:42] Assuming we got our alternatives all done and we've got all that. Then of course we move in to Number 7 which you may want to talk about that on the methods.

Judy Kurtzman: [00:26:55] Okay I do want to say one more thing about the alternative section before we move on and that is to really encourage people to take a look at how they defined the alternative and to see if its obvious which is going to be the preferred alternative because of how it's developed or because of it's four pages long and the other two are half a page each or whatever the case may be. Just take a look and see if you were looking at this from the outside does it feel like the decisions already made before you even move beyond that? So moving in to Chapters 3 and 4 and the methods being used. In the CEQ regs in section 1502.24. They talk about the methodology and scientific accuracy required for these documents an EA or an EIS. I can honestly say that there are many times I've been reading through a document and I'll read chapter one and it'll be really well written and well developed and I'll read Chapter 2 and it'll be really well written. I think I've finally found that EA or that EIS that people have been asking me for. That's a really good example. And then I get into Chapter 3 and 4 and it kind of all falls apart. Because in Chapters 3 and 4 there's no real analysis done. I cant even tell if there's been a site visit by the resource specialist. Because the information is so vague and there is the information often times there's no discussion of methods used to determine current conditions. Did you do sampling? Did you do a survey? Did you do a literature review? There's no or there's no citations which to me is an automatic. You didn't take a hard look.

Rhey Solomon: [00:29:09] Here you are touching on one of my favorite topics and that is when when I'm working with teams, one of the first things I do is before we jump into everybody looking at the effects for fish or socio-economic or whatever it is. I have a whole team construct cost-effect diagrams. Starting with the actions and running them all the way to what I call the social end-point. And that exercise of diagramming that whether it's through a mind mapping or whether it's through flow-charting there are a lot of techniques. But by doing that you really start forcing your subject matter experts to start documenting their assumptions. Understanding where do they make the connection that this action is going to lead to this effect? Where is the research that supports that? Where's the data that supported that? And it forces those discussions to happen where if you don't do that as a team then as you say it starts to fall apart because they haven't described it well in that section which describes their methodology.

Judy Kurtzman: [00:30:29] Because they haven't thought it through really well like your diagramming forces them to do. It forces them to start thinking at it from the big picture perspective and looking at the direct and indirect impact on the various resources, the links between them and which in turn helps set boundaries for their analysis. Because they have a better understanding of their direct and indirect impact for the resources the ecosystems and the communities they are affecting.

Rhey Solomon: [00:31:11] You get specialist I've seen this happen where where they draw these connections that to them are intuitively obvious but to the rest of us they aren't. And so the need to explain those inter-connected connections that get them to that end point. It drives me nuts when they do that.

Judy Kurtzman: [00:31:36] Especially when it feels like they've now set themselves up side of the team. Because the teams together because they're all managing that land and all of those resources ecosystems and communities are linked together. My understanding is NEPA requires us to take that big picture look at the ecosystems we are working in and how when we change something in it it has that domino effect to it. If we're not working together as a team and not looking at things from that perspective the document doesn't really meet it's purpose of helping everybody see what does this mean to each of these resources but also what does it mean to this ecosystem as a whole.

Rhey Solomon: [00:32:31] Yeah Ill ask you the question. I think you know where I am on this. How do you feel about combining the effect of the environment with the environmental effects. Meaning that the traditional chapters 3 and 4. Do you encourage combining those or keeping them separate?

Judy Kurtzman: [00:32:48] I encourage combining them. I think the flow is much more logical. I think the information from the perspective of the resource specialist writing it. I think it makes more sense to them if they're going from here is the current condition to here is how we're changing it. So I really like the combination regardless of whether it's an EA or an EIS.

Rhey Solomon: [00:33:12] Yeah. I'm with you on that. I think it also shortens up the document to get less encyclopedic information up front. In that environment in the the environmental setting section.

Judy Kurtzman: [00:33:27] And repetition. Yeah you know you don't have to go back and discuss how that change is occurring because I might have forgotten between chapters 3 and 4 after I've read through a whole bunch of that stuff.So I think that it shortens the document of things as well as through the what you have said as well as the through ensuring that there is not the encyclopedic going back to the world has created 4.6 billion years ago.

Rhey Solomon: [00:34:04] You get a lot of that. Which then that of course this whole idea of the best methods and the analysis then that takes me to point number eight which is when I get this feedback all the time. Well Rhey I don't know. I don't have the information. I I can't I can't give that to you. Well Ya well the CEQ Regs do provide you where you have unavailable and incomplete information how to fill those voids. So I tell I said look. You have an obligation to discuss the evidence the Good the Bad the Ugly. You got to be honest about that. Tell me what you know tell me what you don't know. Then and only then can you tell me what you think you can't just immediately say here's what I think without exploring here is what I know here's what I don't know. Now given that here's how I can finally make conclusions of what I'm going to conclude in light of all that missing information.

Judy Kurtzman: [00:35:09] Absolutely. Don't forget that last part too because I've seen we don't have the information and therefore it is impossible to make predictions which isn't going to fly in court. That ends up being the situation.

Rhey Solomon: [00:35:26] Absolutely, as I tell SMEs, I say you're not getting paid the big bucks to say we don't know.

Judy Kurtzman: [00:35:33] Right. Right. And people are often surprised when I say you might be surprised as you might be surprised if you do a very thorough literature review, how much information is actually out there. And it never ceases to amaze me when I start talking about a literature review the blank stares that I get. How can we possibly keep up on the literature and my reaction is because you're a scientist and that's what scientists do, you're a resource specialist you should know the most. You know you should have read the most recent articles about the situation for land management or whatever it is that you know part of land management that you are in. You should know the most you know the most current methods for studying things. That's part of your job as a resource specialist. Is to stay upon on the literature and then cite it in your documents to show you know both the contradictory information out there and the information that supports your your findings.

Rhey Solomon: [00:36:49] And as I emphasize to SMEs. I tell them I say you don't have to be exact in your estimate. You can bound it. You could say as an upper bound here's a lower bound then the science doesn't allow us to be precise but we have with some level of confidence somewhere in between. And that's good as long as you explain why you've done what you've done.

Judy Kurtzman: [00:37:18] And I encourage putting in those variances because we don't have enough information to know exactly what the percent of that loss of habitat is going to do to populations. But we tend to have a variance.

Rhey Solomon: [00:37:37] Yeah that takes me then to to the next point which is this business on consulting agencies and the public and I know that's an area of interest to you so always you respond on that. This takes us in to point nine which is about consulting agencies which then provide some level of input to the unknown as well as the public and I know that an area that you have thoughts on so I'm going to let you talk to that.

Judy Kurtzman: [00:38:07] Okay well I'm not sure what they were thinking. But in the CEQ regs it does say that that scoping is not required for environmental assessments but when you think about what scoping is, and it's both public environment but it's much more than that and how you could suggest for an environmental assessment that you don't need to talk to other federal state local tribal entities that might have regulatory responsibilities over your action or that might have information that you need or might serve as cooperative agencies seems utterly ridiculous to me. So of course you need to do scoping and of course you need to do public involvement and one of the I think I think agencies often forget that state agencies and other federal agencies local and tribal really do have good information for them. That can reduce the amount of effort they have to put into it because the studies have already been done and they can just summarize them and cite them and you know like at the NRCS and soils. If you don't have a soil biologist the NRCS has probably already done the study for you and will tell you what kind of soils that you have. So it is incredibly important to me, that aspect of public involvement as well as appropriate public involvement from the general public and by general public I'm referring to the residents, the adjacent landowners, and and other people who care about that particular public land or that public resource.

Rhey Solomon: [00:40:12] In particular given the you know the one federal decision policy coming out of this administration it's even more important that your particularly your consulting agencies. Those that you are either getting licenses, permits or some consultation are brought into the process early that you have those good working relationships and that there are few surprises that come your way that you've done that often and the relationships are built so that you don't have surprises.

Judy Kurtzman: [00:40:49] And that's you know I know that the Trump administration is really encouraging that. But honestly that's something that should have been happening long ago. I mean you should always be starting the NEPA process as early as possible. In order to ensure that the engineers understand the process and also that you are starting those consultations as soon as you can. Like you said for for developing good relationships and not asking people to I'll just do you a favor and get something done in six weeks that should take six months. But also to ensure that your document is not complete until you have all consultations done and not make a decision until you have consultations done. So getting them started as early as possible is important.

Rhey Solomon: [00:41:50] Yeah absolutely. Absolutely. Which takes us to the last point which is now that you've done all this work then and hopefully the analysis is supported with good science. And you spend all this effort, in the end I find the way you keep your records you live and die if you get litigated at all by what's in the record. And I think sometimes your practitioners overlook that just because there's a piece of paper or an e-mail or something that's laying around that that automatically is going to be used by the court. If you get litigated. Well not necessarily.

[00:42:46] One has a a duty if you will to assure that those documents that are important that you have shown within the NEPA array of documents be your appendices, your environmental impact statement, or EA or the decision document of FONSI. That you're aware of those records. Have relied on those records. And then they become a part of the administrative record if you're litigated. And way too often people start gathering up their record after the project is done. And even after they've been litigated then they start looking around to find all those documents to help support the decision. Well that that stuff should have already been gathered, put together, and indexed as part of a record before the decision ever gets written. I find that is another major failing of agencies.

Judy Kurtzman: [00:43:50] I did too. And if you had ever been in a situation where you had to be the person who starts gathering that information after the fact you know what a nightmare it is trying to try to find all the citations in the documents because you have to have a copy of all the citations. That said the documents you cited in your in your EA or EIS. And It is an absolute nightmare to try and do that after the fact and you rarely have a really good administrative record when you're doing it after the fact.

Rhey Solomon: [00:44:32] Yes as you know, we at Shipley Group recently. Because of demand have developed a course on records management just because we found that some of our practitioners have not been diligent and knowing how to index and build that record.

Judy Kurtzman: [00:44:56] Yeah, Yeah, and I strongly encourage people to take that because even if you don't get litigated that record serves, when you want to go back and say you know I cited this, I can't find the copy right now but I bet there's one in that record that you know so or or an old environmental assessment or a programmatic document even if you're not going to be mitigated those administrative records or administered files whatever an agency wants to call them are incredibly important for future documents as well as for your current document.

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